Performed and documented a detailed value chain and functional analysis plus profit-split calculations to support a client's negotiations with a tax authority prelitigation.
Advised a UK-based multinational on historic thin capitalization, and modeled impact of new interest deductibility rules.
Designed and implemented a new brand licensing structure for a FTSE-100 company across its operations worldwide.
Advised a global business on supply chain optimisation and the creation of a single hub for IP, procurement and sales related activities.
Conducted a critical review of a tax authority's profit-split model to support MAP negotiations, and helped develop alternative parameters for calculations.
Drafted expert opinions on a number of cases involving allegations of value-shifting through non-arm's length transfer pricing.
10 October 2018
Senior Director of Economics & Transfer Pricing, Graham Poole, will be speaking at the International Tax Dispute Resolution & Litigation Summit, on the subject of Diverted Profits...
Hogan Lovells Publications
31 July 2018
Published Works
10 February 2017
Diverted profits tax disputes will come into real focus this year. For many early cases, much of the one year ‘review period’ where negotiation and agreement are expected will...
Global Head of Transfer Pricing
London
Partner
Washington, D.C.
Partner
Shanghai
Senior Director – Hogan Lovells Transfer Pricing
London
Senior Director - Economics and Transfer Pricing
London
"Their grasp of commercial realities, the structures we have and our commercial drivers is very strong."
Chambers UK
